Technology Can Help Navigate Allergen Laws in Both US and EU
In the foodservice industry, allergen information management has become a central concern—both for regulatory compliance and for guest safety. While it’s a worldwide concern, it turns out that the approach to allergen disclosure in restaurants, catering, and other foodservice settings differs significantly between the European Union and the United States, creating unique operational challenges and opportunities for innovation.
The EU Allergen Approach
For its part, the European Union enforces some of the world’s most comprehensive allergen labeling laws. Under Regulation (EU) No 1169/2011, all food businesses—including restaurants, caterers, and cafés—are legally required to provide clear, written information about the presence of any of 14 specified allergens in both prepacked and non-prepacked foods. This means that whether a guest is dining at a sit-down restaurant, selecting from a buffet, or ordering takeaway, they must have access to written allergen information—verbal disclosure alone is no longer sufficient.
The regulation mandates that allergens be emphasized in ingredient lists (for example, using bold or italic fonts) and that this information be prominently available at the point of sale, including on buffet tables or via a readily accessible folder or booklet. The EU’s harmonized approach ensures that consumers with allergies can make informed choices wherever they eat, and it places a significant onus on operators to maintain up-to-date, accurate allergen records for every menu item.
The US Allergen Approach
In the United States, the regulatory landscape is more fragmented. The Food Allergen Labeling and Consumer Protection Act (FALCPA) requires packaged foods to disclose the presence of the nine major allergens, but, until recently, there was no federal requirement for restaurants or foodservice establishments to provide allergen information for unpackaged foods. Many restaurants have voluntarily provided allergen information, but practices vary widely.
A significant shift occurred with the 2022 update to the FDA Food Code, which for the first time recommended written notification of the top nine allergens for unpackaged foods served in restaurants, delis, bakeries, and catering operations. However, the Food Code is a model guideline, not federal law; states and localities must choose to adopt it, and adoption is inconsistent and often slow. This patchwork approach means that allergen information might be readily available in one jurisdiction but lacking in another, creating confusion and risk for consumers with allergies.
Operational Challenges and the Role of Technology
For foodservice operators on both sides of the Atlantic, these regulations present practical challenges: tracking allergen information across hundreds of ingredients and recipes, updating menus as suppliers change, and ensuring that all staff are trained and procedures are followed to prevent cross-contamination.
Galley: Bridging the Compliance Gap
This is where platforms such as Galley's Culinary Resource Planning (CRP) Platform become invaluable. Galley’s culinary operating system is designed to centralize and automate allergen management, making compliance with both EU and US regulations far more manageable. Here’s how Galley can help:
Centralized Allergen Tracking: Galley tracks allergens from the ingredient level through to final recipes, ensuring that any change in supplier or ingredient is instantly reflected across all menu items.
Automated, Compliant Labeling: The platform can generate FDA- and EU-compliant allergen labels and menu disclosures, whether for packaged or unpackaged foods, reducing the risk of human error and ensuring up-to-date information is always available.
Real-Time Updates: Any update to an ingredient’s allergen status automatically updates every recipe and menu item that uses it, maintaining data integrity and saving time for dietitians and kitchen staff.
Collaboration and Communication: Galley breaks down silos between dietitians, chefs, and procurement teams, ensuring everyone has access to the latest allergen and nutritional information for every ingredient and recipe.
Cross-Contamination Alerts: The system can flag potential cross-contact risks, supporting staff training and operational protocols to protect guests with allergies.
Meeting the Highest Standards
As allergen regulations tighten and consumer expectations rise, foodservice operators need robust, flexible solutions to ensure compliance and guest safety—no matter where they operate. Galley Solutions provides the technology backbone to meet the highest standards, whether navigating the EU’s stringent written disclosure requirements or adapting to the evolving US regulatory landscape. In a world where a single ingredient can have life-or-death consequences for some guests, the right information, delivered reliably and efficiently, is not just a regulatory box to check—it’s a core part today of foodservice and hospitality.
This menu from “The Church,” in Dublin, prominently lists allergens in the bottom right corner.
